EHS Associates, Inc.
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about the new NESHAP regulation adopted last year by the Environmental
strippers and/or paint products potentially contain Hazardous Air Pollutants
(HAPs). Since you conduct activities covered under the NESHAP regulation,
your company is required to submit either an “Initial Notification Form” or a
“Petition for Exemption Form” no later than January 10th, 2010. Failure to
submit one or the other will result in a violation.
In order to assist you with making a well-informed decision, EHS Associates,
Inc. has completed an exhaustive inventory and audit of all your spray
applied surface coatings. During our audit, we found that you have
products that if left unchanged will require your company to fully implement
the new regulations including submitting the “Initial Notification Form”. I
have attached your (HAP Evaluation) Chart to this e-mail for your
convenience.
At this time, you have two options
Option 1: Make no changes to your current paint and stripping product
inventory and provide the Oregon DEQ with the required “Initial
Notification” form. If you choose this option, we are ready to complete the
required notification form for you. Just let us know and we will get the paper
work going. This option will require you to have a DEQ Permit – as of this
writing the cost of the permit is $720 per year.
Option 2: Review the attached HAPs Evaluation Chart. Contact your paint
supplier to find suitable HAP-free product substitutes for every item on the
chart. If you successfully remove all items listed on the chart from your
facility by the middle of December, we are prepared to complete the
required “Petition for Exemption” form for you. Please let us know if you
choose this option so we can work with you to ensure that the replacement
coatings and strippers are truly HAPs-free. This option will not require you to
have a DEQ permit.
Please feel free to contact me if you have questions about your HAPs
Evaluation Chart or the particular details of this NESHAP regulation.
Mitch
Mitchell K. Wang, PhD.
EHS Associates, Inc.
503-393-0980 (office)
503-932-9207 (cell)